Somali Mn Indict
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Transcript of Somali Mn Indict
UNITED STATES DISTRICT COURTDISTRICT OF MINNESOTA
UNITED STATES OF AMERICA,
Plaintiff,
v.
1. AMINA FARAH ALI, a/k/a Amina Aden,a/k/a Amina Adan,
a/k/a Amina Wadaado, and
2. HAWO MOHAMED HASSAN, a/k/a Halima Hassan,
a/k/a Halimo Hassan,
Defendants.
) INDICTMENT)) (18 U.S.C. § 2339B(a)(1))) (18 U.S.C. § 1001(a)(2))) )) ) ))))))))
THE UNITED STATES GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS
At all times relevant to this indictment:
1. Defendant AMINA FARAH ALI, a/k/a Amina Aden, a/k/a Amina
Adan, a/k/a Amina Wadaado, was a Somali national who became a
United States citizen in August 2004 and lived in Rochester in the
District of Minnesota.
2. Defendant HAWO MOHAMED HASSAN, a/k/a Halima Hassan, a/k/a
Halimo Hassan, was a Somali national who became a United States
citizen in March 2008 and lived in Rochester in the District of
Minnesota.
U.S. v. Amina Farah Ali, et al.
3. Al-Shabaab was a terrorist organization based in Somalia,
whose primary objective was the violent overthrow of the Somali
Transitional Federal Government (“TFG”).
4. On or about February 26, 2008, the U.S. Department of
State designated al-Shabaab as a Foreign Terrorist Organization
(FTO) under Section 219 of the Immigration and Nationality Act, as
amended. The designation remains in effect as of this date. Under
the designation, al-Shabaab is also known as al-Shabab, Shabaab,
the Youth, Mujahidin al-Shabaab Movement, Mujahideen Youth
Movement, Mujahidin Youth Movement, MYM, Harakat Shabab al-
Mujahidin, Hizbul Shabaab, Hisb'ul Shabaab, al-Shabaab al-Islamiya,
Youth Wing, al Shabaab al-Islaam, al-Shabaab al-Jihaad, and the
Unity of Islamic Youth. "Al-Shabaab" is an Arabic word that loosely
translates to "the Youth" and is commonly used in the Somali
language. Al-Shabaab and its members are commonly referred to, and
known as "the Youth," “the young guys,” and “the young men.”
5. Unindicted Conspirator 1 (“UC1") was a member of al-
Shabaab who was an al-Shabaab financial representative and then
became the al-Shabaab administrative governor for the Bay and
Bakool regions in Southern Somalia, after al-Shabaab seized control
of those regions in February 2009.
6. Unindicted Conspirator 2 (“UC2") was a subordinate of
UC1, who received funds sent to al-Shabaab via Somali telephone
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U.S. v. Amina Farah Ali, et al.
number 25215332225.
7. Unindicted Conspirator 3 (“UC3") was a subordinate of
UC1, who received funds sent to al-Shabaab via Somali telephone
number 25215401510.
8. Unindicted Conspirator 4 (”UC4") was a subordinate of
UC1, who received funds sent to al-Shabaab via Somali telephone
numbers 25215104242 and 25215408856.
9. Unindicted Conspirator 5 (“UC5") was a senior member of
al-Shabaab’s women’s department, who conducted lectures and
received funds sent to al-Shabaab via Somali telephone number
25215875171.
10. Unindicted Conspirator 6 (“UC6") was a resident of
Minneapolis, Minnesota, who assisted ALI in collecting and
forwarding funds to al-Shabaab.
11. Unindicted Conspirator 7 (“UC7") was a resident of
Columbus, Ohio who assisted ALI in collecting and forwarding funds
to al-Shabaab.
12. Jihad is an Arabic word which means, among other things,
“holy war.” As used in this indictment, it refers to al-Shabaab’s
and other militias’ efforts to topple the TFG through violence.
13. Mujahidin is an Arabic word which means “holy warriors.”
Mujahid is the singular form of mujahidin.
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U.S. v. Amina Farah Ali, et al.
COUNT 1(Conspiracy to Provide Material Support
to Foreign Terrorist Organization)
14. The allegations set forth in paragraphs 1 through 13 are
realleged and incorporated by reference as though fully set forth
herein.
15. From on or about September 17, 2008, through on or about
July 19, 2009, in the District of Minnesota, and elsewhere, the
defendants,
AMINA FARAH ALI, a/k/a Amina Aden,a/k/a Amina Adan,
a/k/a Amina Wadaado, andHAWO MOHAMED HASSAN,a/k/a Halima Hassan,a/k/a Halimo Hassan,
who were United States citizens, did knowingly conspire,
confederate and agree with each other and with others, known and
unknown to the grand jury, knowingly to provide material support
and resources, namely money, to al-Shabaab, which was designated a
Foreign Terrorist Organization on February 26, 2008, pursuant to
Section 219 of the Immigration and Nationality Act; in violation of
Title 18, United States Code, Section 2339B(a)(1).
Manner and Means
The manner and means by which the conspiracy was sought to be
accomplished included:
16. It was a part of the conspiracy that ALI communicated by
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U.S. v. Amina Farah Ali, et al.
telephone with persons in Somalia, who requested financial
assistance for al-Shabaab.
17. It was further a part of the conspiracy that ALI, HASSAN,
and others raised funds by soliciting door-to-door among Somali
communities located in Rochester and Minneapolis, and elsewhere in
the United States and Canada, some of which funds ALI directed to
al-Shabaab.
18. It was further a part of the conspiracy that ALI, HASSAN,
and others raised funds for al-Shabaab by direct appeal to
participants in teleconferences in which they and other speakers
encouraged financial contributions to support violent jihad in
Somalia, which contributions ALI directed to al-Shabaab.
19. It was further a part of the conspiracy that ALI and
others raised funds for al-Shabaab under the false pretense that
the funds were for the poor and needy.
20. It was further a part of the conspiracy that ALI and
others acting at her direction transmitted funds to al-Shabaab
through the hawala money remittance system, using Dar al Tawakul
General Trading, LLC, a/k/a Tawakal Money Express; Kaah Express,
LLC; Dahabshiil; Dahabshil, Inc.; Qaran Express US, Inc.; Amaana
Money Transfer; and Mustaqbal Express, among others.
21. It was further a part of the conspiracy that ALI and
others used false and fictitious names to identify the recipient of
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U.S. v. Amina Farah Ali, et al.
the funds in order to conceal that the funds were being provided to
al-Shabaab.
Overt Acts
22. On or about September 22, 2008, ALI called UC1 in Somalia
to verify he had received approximately $1060 sent to him under the
name Nimco Ali Mohamed.
23. On or about October 23, 2008, ALI spoke with UC5, who was
in Somalia, asking about the availability of a speaker to address
ALI’s audience in an upcoming teleconference.
24. On or about October 26, 2008, ALI hosted a fund raising
teleconference in which UC5 told the listeners that it was not the
time to help the poor and needy in Somalia; rather, the priority
was to give to the mujahidin.
25. On or about October 26, 2008, ALI and HASSAN recorded
approximately $2,100 in pledges at the conclusion of the
teleconference.
26. On or about November 7, 2008, ALI told UC6, to contact
people from the Minneapolis/St. Paul area, who had pledged
contributions, and to collect those funds.
27. On or about December 6, 2008, ALI told another that she
had sent funds to al-Shabaab stating that she sent the money to the
“brothers, . . . to their account, towards [UC1].”
28. On or about January 12, 2009, ALI directed UC7 to “always
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U.S. v. Amina Farah Ali, et al.
collect under the name of the poor” so that those funds could be
sent to the mujahidin in Somalia.
29. On or about February 10, 2009, ALI conducted another fund
raising teleconference in which she delivered a lecture telling her
listeners to “forget about the other charities” and focus on “the
Jihad.”
30. On or about February 10, 2009, at the conclusion of the
teleconference, HASSAN told the audience that, if they pledged,
their names and contact information would be recorded but that ALI
would be the one to contact them to collect the funds.
31. On or about February 16, 2009, UC1 told ALI that any
funds, regardless of their purpose, should be directed to his
assistant, UC4, at an account number UC4 would provide.
32. On or about February 17, 2009, ALI asked UC1 if she could
make up names to use as the recipients of funds she was sending to
al-Shabaab like she had done in the past.
33. On or about February 23, 2009, ALI directed another
person to send $1000 to al-Shabaab account number 25215401510 using
the false name Shamso Ali Ahmed as the recipient of the funds.
34. On or about April 3, 2009, ALI told HASSAN that the
purpose for the fund raising was to support al-Shabaab, by stating,
“We are with the Youth.”
35. On or about April 17, 2009, ALI directed another to send
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U.S. v. Amina Farah Ali, et al.
$1600 to Somalia using two different hawalas and sending half to
the name Shamso Ali Ahmed and the other half to Maryann Muse Bakar,
at the same telephone number 25215401510.
36. On or about May 20, 2009, ALI contacted UC4 and told her
two transfers totaling $1200 had been sent to a new al-Shabaab
account number ending in 4242, which account number ALI had
received from UC1.
37. On or about July 14, 2009, following the FBI’s execution
of a search warrant at ALI’s residence, ALI contacted UC1 and
stated that “I was questioned by the enemy here. . . . they took
all my stuff and are investigating it. . . do not accept calls from
anyone.”
38. Each of Counts 2 through 13 below is incorporated as an
overt act as if fully set forth herein.
COUNTS 2-13(Material Support to Foreign Terrorist Organization)
39. The allegations set forth in paragraphs 1 through 13
are realleged and incorporated by reference as though fully set
forth herein.
40. On or about the dates alleged below, in the District of
Minnesota, the defendant,
AMINA FARAH ALI, a/k/a Amina Aden,a/k/a Amina Adan,
a/k/a Amina Wadaado,
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U.S. v. Amina Farah Ali, et al.
who was a United States citizen, did knowingly provide and attempt
to provide material support and resources, namely, money in the
approximate amounts alleged below, to al-Shabaab, which was
designated a Foreign Terrorist Organization on February 26, 2008,
pursuant to Section 219 of the Immigration and Nationality Act:
Count Date Amount
2 September 17, 2008 $1063
3 October 30, 2008 $1000
4 November 2, 2008 $ 500
5 February 12, 2009 $ 750
6 February 23, 2009 $1000
7 February 23, 2009 $1000
8 March 10, 2009 $ 550
9 March 14, 2009 $1195
10 May 18, 2009 $ 500
11 May 18, 2009 $ 500
12 May 31, 2009 $ 250
13 July 5, 2009 $ 300
All in violation of Title 18, United States Code, Section
2339B(a)(1).
COUNT 14(False Statement)
41. The allegations set forth in paragraphs 1 through 13 are
realleged and incorporated by reference as though fully set forth
herein.
42. On or about September 2, 2009, in the State and District
U.S. v. Amina Farah Ali, et al.
of Minnesota, in a matter within the jurisdiction of the Federal
Bureau of Investigation, namely an international terrorism
investigation, the defendant,
HAWO MOHAMED HASSAN,a/k/a Halima Hassan,a/k/a Halimo Hassan,
knowingly and willfully made a false material statement and
representation to the FBI in that she stated she did not know
anyone who had sent money to al-Shabaab, the mujahidin, the “Young
Men,” or the fighters; all in violation of Title 18, United States
Code, Section 1001(a)(2).
COUNT 15(False Statement)
43. The allegations set forth in paragraphs 1 through 13
are realleged and incorporated by reference as though fully set
forth herein.
44. On or about September 2, 2009, in the State and District
of Minnesota, in a matter within the jurisdiction of the Federal
Bureau of Investigation, namely an international terrorism
investigation, the defendant,
HAWO MOHAMED HASSAN,a/k/a Halima Hassan,a/k/a Halimo Hassan,
knowingly and willfully made a false material statement and
representation to the FBI in that she stated that Amina Ali had
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U.S. v. Amina Farah Ali, et al.
never asked her to send money to Somalia or elsewhere through a
hawala; all in violation of Title 18, United States Code, Section
1001(a)(2).
COUNT 16(False Statement)
45. The allegations set forth in paragraphs 1 through 13
are realleged and incorporated by reference as though fully set
forth herein.
46. On or about September 14, 2009, in the State and District
of Minnesota, in a matter within the jurisdiction of the Federal
Bureau of Investigation, namely an international terrorism
investigation, the defendant,
HAWO MOHAMED HASSAN,a/k/a Halima Hassan,a/k/a Halimo Hassan,
knowingly and willfully made a false material statement and
representation to the FBI in that she stated that she and Amina Ali
never discussed raising money for the “young men;” all in violation
of Title 18, United States Code, Section 1001(a)(2).
A TRUE BILL
UNITED STATES ATTORNEY FOREPERSON
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